Justia Idaho Supreme Court Opinion Summaries

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This case arose from the division of a three-member accounting firm, Siddoway, Wadsworth & Reese, PLLC. The three members of the firm were the personal professional corporations solely owned by each accountant. In early 2015, Reese PC signed a purchase agreement to buy a one-half interest in the client base of Siddoway PC for $200,000. This purchase agreement included an arbitration clause. In August of 2015, Siddoway left the accounting firm, taking several employees and the clients’ information with him. Following Siddoway’s departure, the firm (now named Wadsworth Reese, PLLC), along with its remaining members, filed a complaint in the district court against Siddoway and his personal professional corporation and two of the employees who followed him. Siddoway counterclaimed. The parties brought a range of claims. Reese PC and Siddoway PC also went to arbitration for claims related to their purchase agreement, but the arbitrator determined the purchase agreement was void for failure of a condition subsequent. The remaining claims between the parties were tried by the district court. The district court ultimately decided to “leave the parties where it found them.” This included final determinations pertinent to this appeal: (1) dissociation of Siddoway’s personal professional corporation as a firm member; (2) Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration; (3) Siddoway PC failed to show unjust enrichment from the void purchase agreement; and (4) the firm could fund Reese’s personal professional corporation’s litigation and arbitration costs because resolving the purchase-agreement dispute served a legitimate business purpose. Siddoway and Siddoway PC appealed. The Idaho Supreme Court affirmed the district court’s judgment: Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration, nor did they show unjust enrichment or breach of membership duties. View "Wadsworth Reese v. Siddoway & Co" on Justia Law

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Mario Ayala was injured while driving a company truck in 2009, and was injured again in 2013 after falling from a ladder. After the hearing, but before the referee issued “recommended findings and determination” in accordance with Idaho Code section 72-717, the Industrial Commission reassigned the case to itself over Ayala’s objection. Citing the referee’s backlog of cases and a need for efficiency, the Industrial Commission issued an order finding that Ayala’s low-back condition was not causally related to his 2009 truck wreck, that he was not totally and permanently disabled under the odd-lot worker doctrine, and that he suffered disability of 40% of the whole person inclusive of impairment of his 2009 and 2013 industrial accidents. The Idaho Supreme Court set aside the Commission’s findings of fact, conclusions of law and order because Ayala was denied due process when the Industrial Commission reviewed Ayala’s claims and issued a decision without the referee’s recommended findings and determination. The Court also set aside the Industrial Commission’s post-hearing order on motion for reconsideration and order on motion for reconsideration, modification and consolidation, and remanded this matter for a new hearing. View "Ayala v. Meyers Farms" on Justia Law

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The State appealed a district court order granting Monica Wolfe’s motion to suppress evidence obtained from a cell phone in her possession.In early 2017, a dog owned by Robert Wolfe and his new wife became unusually lethargic and eventually died. Around that same time, they noticed golf balls in their yard, some of which had been chewed. Because no one in the family played golf and they did not live near a golf course, suspicion arose. As a result, the family initiated an investigation through Animal Control and discovered that the golf balls appeared to have antifreeze residue on them. A veterinarian later confirmed that the dog died due to ingesting antifreeze and golf balls. From this, the family suspected that the dog had been poisoned. Soon after the dog died, Daniel Collins, a man who had dated Robert’s ex-wife, defendant Monica Wolfe, contacted Robert and informed him that he had been solicited by Wolfe to kill Robert and his dog. Robert met with Collins at a restaurant and, unbeknownst to Collins, recorded their conversation. During the conversation, Collins stated that Wolfe asked him to find out when Robert left work so that he could “take [him] out from there.” Regarding the dog, Collins said that he was hoping he could “get to [Robert]” before it died, and that Wolfe’s plan was to mix car antifreeze with meatballs to kill the dog. He further asserted that Wolfe “was asking [him] for help . . . but basically wanted to be the one to have [Robert] underground” because “she [was] angry” with him for obtaining custody of their two kids. After this conversation, Robert contacted the police to report Wolfe and Collins. Wolfe was later interviewed. She also admitted to having a conversation about killing a neighbor’s dog with antifreeze, but denied killing Robert’s dog. Further, she and the detective discussed text messages that were on a cell phone in her possession. The district court held that law enforcement unlawfully seized the phone prior to obtaining a warrant to search it. The State argued the "independent source exception" applied because law enforcement subsequently obtained a valid search warrant that was not tainted by the unlawful seizure, and therefore, the evidence found on the phone should not have been suppressed. The Idaho Supreme Court disagreed and affirmed the district court. View "Idaho v. Wolfe" on Justia Law

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Christopher Shanahan appealed a district court decision denying his motion to correct an allegedly illegal sentence imposed in 1997. In the Fall of 1995, Shanahan and two friends devised a scheme to rob a convenience store in Grant, Idaho, and use the money to travel to Las Vegas, Nevada. Once there, they planned to join a gang and lead a life of crime. Shanahan argued his indeterminate life sentence, with the first thirty-five years fixed, for the murder he committed as a juvenile in 1995 was equivalent to a life sentence without the possibility of parole. Therefore, he argued that under Miller v. Alabama, 567 U.S. 460 (2012) and persuasive precedent from other states, he was entitled to a new sentencing where his youth and its attendant characteristics could be properly considered. Otherwise, he argued, his sentence violated the Eighth and Fourteenth Amendments to the U.S. Constitution. The district court denied the motion on the basis that Miller was inapplicable to Shanahan’s sentence and, even if it applied, the sentencing court heard testimony regarding his age and mental health prior to sentencing him. Finding no reversible error, the Idaho Supreme Court affirmed Shanahan's conviction. View "Idaho v. Shanahan" on Justia Law

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Samantha Cook was pulled over by a police officer after the officer noticed her vehicle lacked both front and rear license plates. As the vehicles slowed to pull over, the officer noticed a piece of paper in the rear window of Cook’s car. Upon approaching the pulled-over vehicle, the officer noticed that the piece of paper was a temporary registration permit, which was unreadable due to condensation from rain earlier in the evening. The officer then spoke with Cook, detected the smell of marijuana, searched her vehicle, located controlled substances, and arrested her. Cook filed a motion to suppress the evidence obtained during the stop on the grounds that the officer lacked probable cause to stop her vehicle. The district court denied Cook’s motion. The district court found, based on Idaho v. Kinch, 356 P.3d 389 (Ct. App. 2015), a reasonable suspicion existed that Cook had violated Idaho Code section 49-432(4), which required a driver to display a permit “upon the windshield of each vehicle or in another prominent place where it may be readily legible.” As a result, the district court found the seizure legal and the evidence obtained after the seizure properly obtained. The Court of Appeals affirmed. Cook argued on appeal, among other things, that the district court erred in denying her motion to suppress because Idaho Code section 49-432(4) was unconstitutionally vague as applied to her conduct. The Idaho Supreme Court concurred, concluding the statute was unconstitutionally vague. The Court reversed the district court’s denial of Cook’s motion to suppress; Cook’s conviction was vacated, and the matter remanded for further proceedings. View "Idaho v. Cook" on Justia Law

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Defendant Shawn Coats was charged with eight different offenses after he took an elderly man’s debit card and deposited fraudulent checks into the man’s credit union account to create funds for a multi-day shopping spree at Walmart. After a jury trial, he was convicted of seven of the offenses, including grand theft of retail goods and fraudulent use of a financial transaction card. On appeal, Coats contended the jury did not have substantial evidence to convict him of grand theft of retail goods from an owner because Walmart was paid in full for the goods, and Morgan, the man from whom he obtained the debit card, never owned the purchases. Alternatively, he argued he was subjected to double jeopardy upon being convicted for both grand theft and fraudulent use of a financial transaction card, because fraudulent use was a lesser included offense of grand theft. The Idaho Supreme Court determined there was not substantial evidence for the conviction of grand theft: "While Idaho’s theft statute is broad and covers many misdeeds, there must be a careful analysis of what was stolen and from whom before a charging decision is made and the jury is instructed." Because this case was remanded to the district court with instructions to vacate Coats’s conviction on grand theft, the Supreme Court did not reach the merits of Coats’s double jeopardy argument. "[I]f the State desired to charge Coats for grand theft relating to the purchases made at Walmart with a debit card, it had to properly allege Coats wrongfully obtained money from the credit union that credited Morgan’s account with funds for the POS transaction. Yet, the State charged Coats with wrongfully obtaining retail goods from an owner—there was not sufficient evidence presented for a jury to convict Coats of this specific crime." View "Idaho v. Coats" on Justia Law

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Jun Yu appealed the dismissal of his claims for alleged violations of 42 U.S.C. section 1983 and breach of contract. Idaho State University dismissed Yu from its doctoral program in clinical psychology in May 2013, with his final administrative appeal denied on October 2, 2013. Yu, a citizen of the People’s Republic of China, was completing his Ph.D. in clinical psychology at Idaho State University. He completed all the requisite coursework, wrote and defended his dissertation, but still had to complete a one-year clinical internship. After not matching any programs with the Association of Psychology Postdoctoral and Internship Centers, Yu set up an alternative internship with the Cleveland Clinic Center for Autism in Ohio. However, he was dismissed from the Ohio internship early due to performance concerns and subsequently dismissed from Idaho State University’s doctoral program. After exhausting his appeals with the university, Yu received a final letter on October 2 that denied his appeal and immediately made his dismissal effective. In March 2014, Yu filed a notice of tort claim against ISU pursuant to the Idaho Tort Claims Act (ITCA), alleging negligent infliction of emotional distress and a violation of Title VI of the 1964 Civil Right Act. Eighteen months later he filed a lawsuit in the U.S. District Court for the District of Idaho alleging violations of Title VI of the Civil Rights Act, deprivation of constitutional rights under 42 U.S.C. section 1983, and negligent infliction of emotional distress. Yu later amended his complaint to include allegations of denial of procedural and substantive due process, promissory estoppel, and breach of contract, totaling 18 claims against ISU. No individual defendants were named in the notice of claim or in his federal action. The Idaho Supreme Court affirmed the district court’s dismissal of Yu’s claims because they were untimely. View "Yu v. ID State University" on Justia Law

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Aspen Park, Inc., a nonprofit organization, sought a property tax exemption from Bonneville County, Idaho for its low-income apartments. The County’s Board of Equalization denied an exemption because some of the apartments were leased to tenants with incomes above 60 percent of the county’s median income level, a requirement set forth in Idaho Code section 63-602GG(3)(c). Aspen Park appealed to the Idaho Board of Tax Appeals, arguing that the statute allowed vacant apartments to be leased to higher-income earners. After the Board of Tax Appeals denied tax exempt status, Aspen Park filed a petition for judicial review with the district court. The district court granted Bonneville County summary judgment after deciding that to be eligible for a tax exemption under Idaho Code section 63-602GG, every apartment must be rented to low-income individuals or remain vacant. Aspen Park appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Aspen Park v. Bonneville County" on Justia Law

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At issue in this case was whether Brent Austin filed a timely complaint for additional worker's compensation benefits with the Idaho Industrial Commission when it was filed more than a year after his employer, Bio Tech Nutrients, and its surety, Employers Compensation Insurance Company, (collectively “Defendants”) stopped paying worker’s compensation benefits. The Commission held that the one-year statute of limitations to file a complaint was tolled because the Defendants did not send a Notice of Claim Status (“NOCS”) when they submitted Austin’s final payment; as such, the Commission concluded Austin’s complaint was timely filed. After review, the Idaho Supreme Court determined the Commission was correct in tolling the statute of limitations, and affirmed. View "Austin v. Bio Tech Nutrients" on Justia Law

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This appeal centered on the distribution of water to water right 95-0734 in the Twin Lakes-Rathdrum Creek Drainage Basin. Sylte Ranch, LLC, was the current claimant on water right 95- 0734, which dated from 1875 and provided natural flow stockwater from Rathdrum Creek. In September 2016, Idaho Department of Water Resources (IDWR) issued a letter of instructions to the local watermaster in response to a complaint that he was releasing storage water from Twin Lakes contrary to a 1989 Final Decree that established all existing rights to Twin Lakes’ surface waters, tributaries, and outlets. These instructions led Sylte to file a Petition for Declaratory Ruling, arguing that IDWR should set aside and reverse the instructions because they improperly limited water right 95-0734 to Twin Lakes’ natural tributary inflow. Twin Lakes Improvement Association, et al., and Twin Lakes Flood Control District intervened in the case. Following cross motions for summary judgment, IDWR issued a Final Order, in which it upheld the instructions and granted intervenors’ motion for summary judgment. Sylte then sought judicial review and the district court affirmed IDWR’s Final Order. Sylte timely appealed to the Idaho Supreme Court. The Supreme Court affirmed the district court’s determination to uphold IDWR’s Final Order because the instructions complied with the plain language of the 1989 Final Decree. View "Sylte v. IDWR" on Justia Law